IR 05000334/2009003

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August 4, 2009

Mr. Peter P. Sena, III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station P. O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT: BEAVER VALLEY POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000334/2009003 AND 05000412/2009003

Dear Mr. Sena:

On June 30, 2009, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station Units 1 and 2. The enclosed integrated inspection report documents the inspection results which were discussed on July 22, 2009, with members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, this report documents one NRC-identified finding and one self-revealing finding, both of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation which was determined to be of low safety significance is listed in this report. However, because of the very low safety significance and because the issues have been entered in the corrective action program, the NRC is treating the findings as non-cited violations (NCVs)

consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any of the findings in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Beaver Valley. In addition, if you disagree with the characterization of the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1 and the NRC Senior Resident Inspector at the Beaver Valley Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosures, and your response (if any) will be available electronically for public inspection in the P. Sena, III 2 NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questions regarding this letter.

Sincerely,/RA/

Ronald R. Bellamy, Ph.D., Chief Reactor Projects Branch 6 Division of Reactor Projects

Docket Nos.: 50-334, 50-412 License Nos: DPR-66, NPF-73

Enclosures:

Inspection Report 05000334/2009003; 05000412/2009003

w/Attachment:

Supplemental Information cc w/encl:

J. Hagan, President and Chief Nuclear Officer J. Lash, Senior Vice President of Operations and Chief Operating Officer D. Pace, Senior Vice President, Fleet Engineering K. Fili, Vice President, Fleet Oversight P. Harden, Vice President, Nuclear Support G. Halnon, Director, Fleet Regulatory Affairs Manager, Fleet Licensing Company R. Lieb, Director, Site Operations D. Murray, Director, Maintenance M. Manoleras, Director, Engineering R. Brosi, Director, Site Performance Improvement C. Keller, Manager, Site Regulatory Compliance D. Jenkins, Attorney, FirstEnergy Corporation M. Clancy, Mayor, Shippingport, PA D. Allard, Director, PADEP C. O'Claire, State Liaison to the NRC, State of Ohio Z. Clayton, EPA-DERR, State of Ohio Director, Utilities Department, Public Utilities Commission, State of Ohio D. Hill, Chief, Radiological Health Program, State of West Virginia J. Lewis, Commissioner, Division of Labor, State of West Virginia W. Hill, Beaver County Emergency Management Agency J. Johnsrud, National Energy Committee, Sierra Club P. Sena, III 3 NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questions regarding this letter.

Sincerely,/RA/ Ronald R. Bellamy, Ph.D., Chief Reactor Projects Branch 6 Division of Reactor Projects

Distribution w/encl: S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP R. Bellamy, DRP G. Barber, DRP C. Newport, DRP J. Greives, DRP D. Werkheiser, DRP, SRI D. Spindler, DRP, RI P. Garrett, DRP, Resident OA L. Trocine, RI OEDO R. Nelson, NRR N. Morgan, PM, NRR R. Guzman, NRR S. West, DRS-RIII C. Pederson, DRP-RIII ROPreportsResource@nrc.gov Region I Docket Room (with concurrences)

ML092160021 SUNSI Review Complete: RRB (Reviewer's Initials) DOCUMENT NAME: G:\DRP\BRANCH6\+++BEAVER VALLEY\BV INSPECTION REPORTS & EXIT NOTES\ BV INSPECTION REPORTS 2009\BVREPORT-IR2009-003.DOC After declaring this document "An Official Agency Record" it will be released to the Public . To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRP RI/DRP NAME DWerkheiser/DW RBellamy/ RRB DATE 07/29/09 08/04/09 OFFICIAL RECORD COPY 1 Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION I

Docket Nos. 50-334, 50-412

License Nos. DPR-66, NPF-73

Report Nos. 05000334/2009003 and 05000412/2009003

Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Beaver Valley Power Station, Units 1 and 2

Location: Post Office Box 4 Shippingport, PA 15077

Dates: April 1, 2009 through June 30, 2009

Inspectors: D. Werkheiser, Senior Resident Inspector D. Spindler, Resident Inspector J. Ayala, Resident Inspector P. Kaufman, Senior Reactor Inspector T. Moslak, Health Physicist O. Ayegbusi, Reactor Inspector Approved by: R. Bellamy, Ph.D., Chief Reactor Projects Branch 6 Division of Reactor Projects

2 Enclosure TABLE of

SUMMARY OF FINDINGS

.............................................................................................................. 3

REPORT DETAILS

..........................................................................................................................

REACTOR SAFETY

............................................................................................................ 5 1R01 Adverse Weather Protection ) ..................................................................................... 5 1R04 Equipment Alignment ................................................................................................. 6 1R05 Fire Protection ............................................................................................................ 7 1R06 Flood Protection Measures .......................................................................................... 8 1R08 Unit 1 Inservice Inspection .......................................................................................... 8 1R11 Licensed Operator Requalification Program ............................................................ 11 1R12 Maintenance Rule Implementation ........................................................................... 11 1R13 Maintenance Risk Assessment and Emergent Work Control .................................. 12 1R15 Operability Evaluations ............................................................................................. 12 1R18 Plant Modifications .................................................................................................... 13 1R19 Post-Maintenance Testing ........................................................................................ 14 1R20 Refueling and Outage Activities ............................................................................... 16 1R22 Surveillance Testing

RADIATION SAFETY

............................................................................................................... 17 2OS1 Access Control to Radiologically Significant Areas .................................................. 17 2OS2 ALARA Planning and Controls

OTHER ACTIVITIES

[OA] ..................................................................................................... 21

4OA1 Performance Indicator Verification

........................................................................... 21

4OA2 Problem Identification and Resolution

...................................................................... 22

4OA3 Followup of Events and Notices of Enforcement Discretion

.................................... 25

4OA5 Other Activities ........................................................................................................... 26 4OA6 Meetings, Including Exit ............................................................................................. 27 4OA7 Licensee-Identified Violations .................................................................................... 28

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

...................................................................................................... A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

.......................................................... A-1

LIST OF DOCUMENTS REVIEWED

.......................................................................................... A-2

LIST OF ACRONYMS

............................................................................................................... A-10

Enclosure

SUMMAR Y
OF [[]]
FINDIN [[]]
GS [[]]
IR 05000334/2009003,

IR 05000412/2009003; 04/01/2009 - 06/30/2009; Beaver Valley Power

Station, Units 1 & 2; Post-Maintenance Testing, Problem Identification and Resolution

The report covered a 3-month period of inspection by resident inspectors, regional reactor

inspectors, and a regional health physics inspector. Two (GREEN) findings were identified. The

significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter (IMC) 0609,

AS ignificance Determination Process@ (
SDP ). Findings for which the
SDP does not apply may be Green or be assigned a severity level after

NRC management review. Cross-cutting aspects associated with findings are determined using IMC

0305, "Operating Reactor Assessment Program," dated January 2009. The NRC's program for

overseeing the safe operation of commercial nuclear power reactors is described in

NUR [[]]

EG-

1649,

AR eactor Oversight Process,@ Revision 4, dated December 2006. Cornerstone: Mitigating Systems * Green. A non-cited violation (

NCV) of 10CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" was identified for failure to specify and perform

an adequate post-maintenance test (PMT) after replacing a safety-related river water

check-valve. Specifically, the PMT under work order 200233562 was not adequate to

verify the proper function of the valve

1RW -57 prior to its return to service. The

PMT was

subsequently performed successfully. This issue was entered into the licensee's

corrective action program as condition report 09-59866. The failure to specify and perform an adequate PMT after replacing a safety-related river

water check-valve was a performance deficiency. The finding was more than minor in

accordance with IMC 0612, Appendix B (Section 1-3), "Issue Screening," because the

failure to specify and perform an adequate PMT is associated with the procedure quality

performance attribute of the mitigating systems cornerstone and affects the associated

cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

This finding has a cross-cutting aspect in the area of human performance associated

with resources because the licensee did not have complete, accurate, and up-to-date

maintenance work procedures [IMC 0305 Aspect:

H. [[2(c)] (Section 1R19). * Green. The inspectors identified a non-cited violation (]]
NCV ) of
10CFR Part 50, Appendix B, Criterion
III , "Design Control," in that
FENOC failed to maintain safety-related cables in an environment for which they were designed. Since

NRC Information

Notice 2002-12 was issued,

FEN [[]]

OC has had several opportunities to trend as-found

data, implement effective maintenance programs, and identify and thoroughly evaluate

long-term adverse conditions for underground safety-related cables exposed to

continuous submerged environments. Cables affected include those for Unit 1 river

water and Unit 2 service water. The issue was entered into the licensee's corrective

action program (CR 09-60496) to initiate a review of the current manhole and cable

monitoring programs, and to initiate long-term corrective actions.

Enclosure Failure to maintain safety related cables in an environment for which they were designed is considered a performance deficiency. The finding was more than minor in accordance

with IMC 0612, Appendix B (Section 1-3), "Issue Screening," because if left uncorrected,

the performance deficiency has the potential to lead to a more significant safety concern.

Specifically, the deficiency did not result in the present loss of operability or functionality and did not represent a risk significant external event such as flooding. The issue was

entered into the licensee's corrective action program (CR 09-60496) to initiate a review of

the current manhole and cable monitoring programs, and to initiate long-term corrective

actions.

The performance deficiency had a cross-cutting aspect in the area of Problem

Identification and Resolution, Corrective Action Program, because the licensee did not

thoroughly evaluate problems such as resolutions, address causes, and evaluate the

effectiveness of corrective actions [IMC 0305 Aspect:

P. [[1 (c)] (Section 4]]

OA2.3). Other Findings A violation of very low safety significance, which was identified by the licensee, has been

reviewed by the inspectors. Corrective actions taken or planned by the licensee have

been entered into the licensee's corrective action program. This violation and corrective

actions are listed in Section 4OA7 of this report.

Enclosure

REPORT [[]]

DETAILS Summary of Plant Status: Unit 1 began the inspection period at 100 percent power. On April 1, the unit began a

planned coastdown, on April 16 reduced power to 82 percent for planned condenser

waterbox cleaning, and shut down on April 19 to commence a refueling outage (1R19).

On May 21, the unit was restarted and synchronized to the grid, achieving full power on

May 24. The unit remained at 100 percent power for the remainder of the inspection

period. Unit 2 began the inspection period at 100 percent power. On April 18, the unit was

down-powered to 97 percent for planned turbine valve testing and returned to full power

later the same day. On May 30 through May 31 the unit was reduced to 96 percent to

address first-point feedwater heater level control issues and returned to full power. The

unit remained at 100 percent power for the remainder of the inspection period.

1.

REACTO R

SAFETY Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity [R]

1R01 Adverse Weather Protection (71111.01)

.1 Seasonal Susceptibility

a. Inspection Scope (2 samples - Hot Weather / Hurricane, Offsite and Alternate

AC Power System Readiness) The inspectors reviewed the Beaver Valley Power Station (
BVPS ) design features and
FEN [[]]

OC's implementation of procedures to protect risk significant mitigating systems from

adverse weather effects due to summer weather and hurricanes. The inspectors

conducted interviews with various station personnel to gain insights into the station's hot

weather and hurricane readiness and reviewed the status of various work orders

categorized as warm weather preparation activities. The inspectors reviewed the

corrective action program database, operating experience, and the Updated Final Safety

Analysis Report (UFSAR), to determine the types of adverse weather conditions to which

the site is susceptible, and to verify that the licensee was appropriately identifying and

resolving weather-related equipment problems.

The inspectors also reviewed

BVPS design features and

FENOC's implementation of

procedures to handle issues that could impact offsite and alternating current (AC) power

systems. The inspectors reviewed

FEN [[]]

OC's procedures and programs which discussed

the operation and availability/reliability of offsite and alternate AC power systems during adverse weather. The inspectors verified that communication protocols between the

transmission system operator and

FEN [[]]

OC existed, and the appropriate information

would be conveyed when potential grid stress and disturbances existed. The inspectors

also verified that

FEN [[]]

OC's procedures contained actions to monitor and maintain the

availability/reliability of offsite and onsite power systems prior to and during adverse weather conditions.

Enclosure b. Findings No findings of significance were identified.

1R04 Equipment Alignment (71111.04)

.1 Partial System Walkdowns (71111.04Q)

a. Inspection Scope (4 samples) The inspectors performed four partial equipment alignment inspections during conditions

of increased safety significance, including when redundant equipment was unavailable

during maintenance or adverse conditions. The partial alignment inspections were also

completed after equipment was recently returned to service after significant

maintenance. The inspectors performed partial walkdowns of the following systems,

including associated electrical distribution components and control room panels, to verify

the equipment was aligned to perform its intended safety functions: * Unit 1, on April 14, emergency diesel generator No. 1 during the performance of

1OST -36.2, "Diesel Generator No. 2 Monthly Test;" * Unit 1, on April 16, train 'A' high head safety injection during the performance of 1

OST-7.19D, "Safety Injection Relay Test (Slave Relay K610)-Train B;" * Unit 1, on April 21, train 'B' residual heat removal system while 'A' electrical train was cleared for maintenance; and * Unit 1, on April 29, containment penetrations during the core reload.

b. Findings No findings of significance were identified.

.2 Complete System Walkdown (71111.04S)

a. Inspection Scope (2 samples) The inspectors performed complete system walkdowns of the following systems to verify

that the critical portions, such as valve positions, switches, and breakers, were correctly

aligned in accordance with procedures, and to identify any discrepancies that may have

had an effect on operability.

The inspectors also reviewed outstanding maintenance work orders to verify that the

deficiencies did not significantly affect the system function. In addition, the inspectors

discussed system health with the system engineer and reviewed the condition report

database to verify that equipment alignment problems were being identified and

appropriately resolved. Documents reviewed during the inspection are listed in the

Attachment. * On June 4, alignment and condition of the Unit 2 'C' service water pump and 'A' service water train while the 'D' main intake bay (affecting the 'A' service water

pump) was out of service for planned cleaning; and

Enclosure * On June 6, alignment of 'A' and 'B' motor-driven auxiliary and dedicated feedwater pumps while the turbine-driven feedwater pump was out of service for

planned maintenance.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05)

.1 Quarterly Sample Review (71111.05Q)

a. Inspection Scope (7 samples) The inspectors reviewed the conditions of the fire areas listed below, to verify compliance

with criteria delineated in Administrative Procedure 1/2-ADM-1900, "Fire Protection,"

Rev. 19. This review included

FEN [[]]

OC's control of transient combustibles and ignition

sources, material condition of fire protection equipment including fire detection systems,

water-based fire suppression systems, gaseous fire suppression systems, manual

firefighting equipment and capability, passive fire protection features, and the adequacy of compensatory measures for any fire protection impairments. Documents reviewed are

listed in the Attachment: * Unit 2,

TR -
MT -2 Main Transformer (Fire Area
TR -1); * Unit 2,
TR -2C Unit Station Service Transformer (Fire Area
TR -2); * Unit 2,
TR -2D Unit Station Service Transformer (Fire Area
TR -3); * Unit 1,
AE Switchgear Room, Battery Rooms 1& 3 (Fire Area
ES -1); * Unit 1,
DF Switchgear Room, Battery Rooms 2& 4 (Fire Area
ES -2); * Unit 1, Reactor Containment (Fire Area

RC-1); and * Unit 1, Rod Control Motor Generator Room (Fire Area MG-1)

b. Findings No findings of significance were identified.

.2 Annual Fire Drill Observation (71111.05A)

a. Inspection Scope (1 sample) The inspectors observed personnel performance during response to an indicated fire in

the Emergency Response Facility sub-station (also see Section 40A3.1) by the fire brigade on June 18. The inspection evaluated the station's demonstration of readiness

in fire fighting response. The inspectors observed the fire brigade members using

protective clothing, turnout gear, and self-contained breathing apparatus and entering the

fire area in a controlled manner. The inspectors also observed the fire fighting

equipment brought to the fire scene to evaluate whether sufficient equipment was

available to effectively control and extinguish the simulated fire. The inspectors

evaluated whether the permanent plant fire hose lines were capable of reaching the fire

area and whether hose usage was adequate. The inspectors observed the fire fighting

directions and communications between fire brigade members. The inspectors verified

Enclosure that the pre-fire plan was used and observed the post-event critique to evaluate fact-finding, lessons-learned and whether any immediate deficiencies needed addressed.

b. Findings No findings of significance were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope (1 sample - underground cables) The inspectors reviewed a sample of internal flood protection measures regarding cables

located in underground manholes. The inspectors selected a

FEN [[]]

OC inspection of

manholes 8A and 8B that contain Unit 1 and Unit 2 safety-related power and control

cables near the main intake structure. These cable manholes are underground and also

the focus of a focus problem identification and resolution review (see section 4OA2.3).

This review was conducted to evaluate

FEN [[]]

OC's protection of the enclosed safety-

related systems from internal flooding condition. The inspectors entered the confined

area with

FEN [[]]

OC personnel, inspected the manhole, and monitored licensee

maintenance activities. The inspectors also reviewed the

UFS [[]]

AR, related internal

flooding evaluations, and other related documents. The inspectors examined the as-

found equipment and conditions to ensure that they remained consistent with those

indicated in the design basis documentation, flooding mitigation documents, and risk

analysis assumptions. Documents reviewed during the inspection are listed in the

Attachment.

b. Findings One finding of significance was identified and documented in section 4OA2.3.

1R08 Unit 1 Inservice Inspection (IP 71111.08)

a. Inspection Scope (1 sample) The purpose of this inspection was to assess the effectiveness of the licensee's in-

service inspection (ISI) program for monitoring degradation of the reactor coolant system

boundary, risk significant piping system boundaries, and the containment boundary for

Unit 1. The inspector assessed the inservice inspection activities using the criteria

specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure

Vessel Code, Section

XI and applicable

NRC Regulatory Requirements. The inspector

selected a sample of nondestructive examination (NDE) activities from the Unit 1 in-

service inspection plan for the 1R19 outage for observation, documentation and record

review, and evaluation for compliance with the requirements of the

BV [[]]

PS Unit 1 Risk-

Informed Inservice Inspection Program and

ASME Section

XI. A sample of activities

associated with the repair/replacement of safety related pressure boundary components

was also reviewed. The sample selection was based on the inspection procedure

objectives, risk significance, availability, and specifically on components and systems where degradation would result in a significant challenge to the integrity of pressure

boundary components. The inspector also conducted a review of TI 2515/172, Reactor

Coolant System Dissimilar Metal Butt Welds for Beaver Valley Power Station Unit 1.

Enclosure The inspector reviewed in-process

NDE , examination data records, deficiency reports and interviewed

NDE personnel to evaluate the technician skills and performance, test equipment capabilities, and examination techniques and to verify that the activities, including calibration, set-up, examination techniques, data analysis, and that indications

and defects were evaluated and dispositioned in accordance with

AS [[]]

ME Boiler and

Pressure Vessel Code, 2001 Edition to 2003 Addenda Section

XI , relevant

ASME Code

Cases, selected relief requests,

BV [[]]

PS Unit 1 Risk-Informed Inservice Inspection

Program, the Materials Reliability Program (MRP) recommendations, and compliance with 10CFR 50.55a.

The inspector also verified that observed indications and deficient conditions were being

adequately entered and dispositioned in the

BV [[]]

PS corrective action program.

Non-Destructive Examination (NDE) and Welding Activities

The following dye penetrant testing (PT), ultrasonic testing (UT), magnetic particle testing

(MT), and visual testing (VT) activities performed during 1R19 outage were reviewed by

the inspector.

The inspector observed and reviewed a sample of NDE examinations and

documentation records of manual

UT examination of reactor coolant system (

RCS) 'A'

loop cold and hot leg nozzle-to-safe-end dissimilar metal (DM) welds

RC -E-1A-N11 and
RC -E-1A-N12 and
RCS 'C' loop cold leg pipe girth weld
DLW -

LOOP3-7-S-02 performed

as follow-up UT examination for a flaw indication initially identified in March 1996. The

inspector reviewed visual bare metal inspections (BMI) records and photos of the Unit 1

reactor pressure vessel lower head penetration nozzles. The resident inspection staff

directly observed VT boric acid walk-down inspections inside the Unit 1 containment.

The inspector also performed a document review of UT thickness examination data

records of the Unit 1 containment liner, which was an examination in the area around a

through-wall hole that was identified during 1R19 outage and magnetic particle and UT

examinations of the liner replacement repairs, UT thickness examination data records of

the Unit 1 containment liner area #3, and PT examination data record of residual heat

removal (RHR) welded attachment RH-1-1-A-02.

Qualified

FEN [[]]

OC inspectors visually examined the condition of accessible portions of the

containment, including the inside surface of the containment liner for corrosion,

mechanical damage and other degradation mechanisms during the 1R19 outage. As a

result of an observed blister in the protective paint coating and protruding rust on the

inside surface of the containment liner at the 738' elevation, a work order was written to

clean the area to allow further evaluation. The cleaning activity uncovered a through-wall

corrosion rectangular hole approximately 1" (horizontal) x 3/8" (vertical) in the

containment liner which was documented in CR 09-57589 and 09-57762 and reported to

the

NRC per 10

CFR50.72 on April 23, 2009. Manual UT thickness examinations of the

containment liner of the affected area were taken as part of

ASME Section

XI,

Subsection IWE to determine the extent of the liner corrosion. The inspectors observed

various aspects of the containment liner NDE inspections, liner plate replacement, repair

welding, and testing activities during the 1R19 outage. A more detailed inspection and

assessment of the containment liner through-wall corrosion hole is documented in

inspection report 05000334/2009006.

Enclosure The inspector examined disposition for continued operation, without repair or rework, of non-conforming condition indications identified during 1R19 outage ISI activities. The

inspector reviewed a liquid penetrant (PT) examination report PT-09-1003 and evaluation

report

EV -09-1002 of welded attachment

RH-1-1-A-02, located on an RHR system elbow

for spring can hanger SH-40, which identified a liner indication at the attachment/elbow

interface area that was determined acceptable after light filling of the surface indication.

Repair/Replacement Consisting of Welding

Ultrasonic (UT) examinations performed on base material per the Materials Reliability

Program (MRP) MRP-146 recommendations identified two circumferential indications

approximately 3/8 inches in length in the stainless steel base material adjacent to a

socket weld on the horizontal portion of

BV -1

RC-41, a 2-inch drain line connected to the

"A" reactor coolant system (RCS) Hot Leg. The deficient condition was documented in

CR 09-58004 and work order 200367565 was initiated to replace the affected piping

segment of the 2-inch drain line. To verify suitability of materials, welding activities

performed, applicable

NDE performed, and

ISI implementing procedures were in

accordance with the

AS [[]]

ME code requirements the inspector reviewed the work scope,

activity sequence, weld filler metal selection, welding procedure, non-destructive examination tests, acceptance criteria and post work testing.

Reactor Pressure Vessel Lower Head Penetration Nozzle Inspection

The inspector verified the inspection results of the visual BMI of the Unit 1 reactor

pressure vessel lower head penetration nozzles that was conducted by

VT -qualified
FEN [[]]

OC personnel during 1R19 by reviewing visual inspection documentation record

results and photos of the BMI inspection. No boric acid leakage was observed around

the annulus area on the 43 penetrations inspected.

Pressurized Water Reactor Vessel Upper Head Penetration Inspection

No inspections were performed of the

BV [[]]

PS Unit 1 reactor vessel upper head during

1R19 outage because the Unit 1 reactor vessel head was replaced in 2006 during 1R17

outage. The inspector reviewed applicable

NRC Regulatory Requirements and

ASME

Code,Section XI, to verify that no examinations were required of the Unit 1 reactor

vessel upper head.

Boric Acid Corrosion Control (BACC) Inspection Activities

The inspector discussed the boric acid control program controlled by

BV [[]]
PS procedure
NOP -

ER-2001, Boric Acid Corrosion Control Program with the boric acid corrosion

control program owner and sampled photographic inspections of boric acid found on

safety significant piping and components inside Unit 1containment during Mode 3 walk

downs conducted by

FEN [[]]

OC personnel in April 2009. The walk down was directly

observed by the resident inspection staff, to verify that the visual inspections were

performed in accordance with the procedure and checklists which emphasized the areas

and locations where boric acid leaks could cause degradation of safety significant

components and that deficient conditions were identified and documented.

Approximately 138 locations were identified with boric acid during 1R19 walk down

inspections.

Enclosure A sample of engineering evaluations/corrective actions associated with these boric acid deficiencies and a sample of these items on the Unit 1 mode hold list were reviewed by

the inspector. The inspector confirmed that condition reports were assigned corrective

actions consistent with the requirements of the

ASME Code and 10

CFR 50, Appendix B,

Criterion XVI. The inspector reviewed various condition reports and work orders to

resolve the identified deficient boric acid conditions.

Steam Generator (SG) Tube Inspections The inspectors reviewed the

BV [[]]

PS Unit 1 1R18 steam generator degradation

assessment

SG -
CDME -07-24. No inspections were performed of the
BV [[]]

PS Unit 1

steam generator tubes during 1R19 outage because the Unit 1 steam generators were

replaced in 2006 during 1R17 outage. The inspector reviewed applicable

NRC Regulatory Requirements and the
ASME Code Section

XI to verify that no examinations

were required during 1R19.

Problem Identification and Resolution The inspector reviewed a sample of condition reports related to

ISI ,

MRP-139, and MRP-

146 program activities to assess

FEN [[]]

OC's effectiveness in problem identification and

resolution and determined that deficiencies are being appropriately identified, and

entered into and resolved by the corrective action program.

1R11 Licensed Operator Requalification Program (71111.11Q)

a. Inspection Scope (1 sample) The inspectors observed Unit 2 licensed operator simulator training on June 23. The

inspectors evaluated licensed operator performance regarding command and control,

implementation of normal, annunciator response, abnormal, and emergency operating

procedures, communications, technical specification review and compliance, and

emergency plan implementation. The inspectors evaluated the licensee staff training

personnel to verify that deficiencies in operator performance were identified, and that

conditions adverse to quality were entered into the licensee's corrective action program

for resolution. The inspectors reviewed simulator physical fidelity to assure the simulator

appropriately modeled the plant control room. The inspectors verified that the training

evaluators adequately addressed that the applicable training objectives had been

achieved.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation (71111.12Q)

a. Inspection Scope (2 samples) The inspectors evaluated Maintenance Rule (MR) implementation for the issues listed

below. The inspectors evaluated specific attributes, such as MR scoping,

characterization of failed structures, systems, and components (SSCs), MR risk

characterization of

SSC s,

SSC performance criteria and goals, and appropriateness of

Enclosure corrective actions. The inspectors verified that the issues were addressed as required by

10 CFR 50.65 and the licensee's program for
MR implementation. For the selected
SSC s, the inspectors evaluated whether performance was properly dispositioned for

MR

category (a)(1) and (a)(2) performance monitoring. MR System Basis Documents were

also reviewed, as appropriate.

  • Unit 1, Solid State Protection System does not achieve
MR a(1) goals, as documented in
CR 09-59359; and * Unit 1,
1CCP -P-1A, head ratio greater than acceptance criteria as documented in

CR 09-60127.

b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessment and Emergent Work Control (71111.13)

a. Inspection Scope (5 samples) The inspectors reviewed the scheduling and control of five activities, and evaluated

their effect on overall plant risk. This review was conducted to ensure compliance with

applicable criteria contained in 10 CFR 50.65(a)(4). Documents reviewed during the

inspection are listed in the Attachment. * On April 20, Unit 1 refueling outage defense-in-depth report re-assessment for changes in calculated time-to-boil values, as document in

CR 09-57463; * On April 21, Unit 1 yellow shutdown risk during

EDG 1-1 autoload test; * On May 3, Unit 1 change in shutdown risk profile for repairs to "B" Residual Heat Removal Pump (1DRH-P-1A) (CR 09-58513); * Week of June 1, Unit 1 and Unit 2, review of station risk during planned 'D' main intake bay cleaning; and * During June 15-21, Unit 1 and Unit 2, review of changed and emergent work coordination for that planned week's activities, including a review of station

processes and procedures for risk determination. b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope (6 samples) The inspectors evaluated the technical adequacy of selected immediate operability determinations (IOD), prompt operability determinations (POD), or functionality assessments (FA), to verify that determinations of Technical Specifications (TS)

operability were justified, as appropriate. In addition, the inspectors verified that

TS limiting conditions for operation (
LCO ) requirements and
UFS [[]]

AR design basis

requirements were properly addressed. In addition, the inspectors reviewed

Enclosure compensatory measures implemented to ensure the measures worked and were adequately controlled. Documents reviewed are listed in the Attachment. * April 12 -14, Unit 1 turbine-driven auxiliary feedwater pump (FW-P-2) steam isolation valve (MOV-1MS-105) failed to open electrically as documented in

CR 09-57106; * On April 15, Unit 1 & 2, licensee's review and assessment of
NRC Regulatory Issue Summary 2009-02 documented in
CR 09-57275; * On April 21, Unit 1 primary component cooler inlet temperature indicator failure to containment penetration cooling coils documented in
CR 09-57667; * On April 23, Unit 1 containment liner plate degradation documented in
CR s 09-57589, 09-57762; * On May 6, Unit 1 emergency diesel generator 1-2 original governor re-installation due to issues documented in
CR 09-58435; and * On June 16, Unit 2 licensee's functional assessment regarding fire protection safe shutdown report analysis of station air documented in

CRs 09-60058, 09-

60162, 06-6932.

b. Findings No findings of significance were identified.

1R18 Plant Modifications (71111.18) .1 Temporary Plant Modifications

a. Inspection Scope (2 samples) The inspectors reviewed the following temporary modifications (TMOD) based on risk

significance. The

TMOD and associated 10

CFR 50.59 screening were reviewed against

the system design basis documentation, including the

UFSAR and the

TS. The

inspectors verified the

TM [[]]

ODs were implemented in accordance with Administrative

(ADM) Procedure, 1/2-ADM-2028, "Temporary Modifications," Rev. 9. Documents

reviewed are listed in the Attachment. *

TMOD [[]]

ECP 09-0174 to provide an alternate discharge path for Unit 1 river water from the outlet of 'A' emergency diesel generator heat exchanger (1EE-E-1A) to

the normal discharge catch basin; and *

TMOD [[]]

ECP 09-01453 to provide additional mitigating configuration and control of plant operations during solid plant operation while shutdown.

b. Findings No findings of significance were identified.

.2 Permanent Plant Modifications

a. Inspection Scope (1 sample)

Enclosure The inspectors evaluated the design basis impact of the modification to the Unit 1 reactor trip breaker circuit under ECP 08-0134-002. The inspectors reviewed the adequacy of

the associated 10 CFR 50.59 screening, verified that attributes and parameters within

the design documentation were consistent with required licensing and design bases, as

well as credited codes and standards, and observed portions of the modification to verify

that changes described in the package were appropriately implemented. The inspectors

also verified the post-modification testing was satisfactorily accomplished to ensure the

system and components operated consistent with their intended safety function.

Documents reviewed are listed in the Attachment.

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope (7 samples) The inspectors reviewed the following activities to determine whether the post-

maintenance tests (PMT) adequately demonstrated that the safety-related function of the

equipment was satisfied given the scope of the work, and that operability of the system was restored. In addition, the inspectors evaluated the applicable acceptance criteria to

verify consistency with the design and licensing bases, as well as TS requirements. The

inspectors witnessed the test or reviewed test data to verify results adequately

demonstrated restoration of affected safety functions. The inspectors also verified that

conditions adverse to quality were entered into the corrective action program for

resolution. Documents reviewed during the inspection are listed in the Attachment. * On April 3,

1OST -30.3, after planned maintenance on Unit 1 'B' train river water; * On April 14, Unit 1, new-fuel frame hoist motor (1
FN -W-1-MOTOR) cable replacement; * On April 21, Unit 1, replacement and retest of
VSR 2 in No.1-1 emergency diesel output breaker (4
KVS [[-1AE-1E9) control circuit; * On May 6, Unit 1, emergency diesel generator No. 1-2 (1EE-EG-2) governor replacement; * On May 8, Unit 1, final painting and baseline volumetric scan after containment plate liner repair; * On May 19, Unit 1, replacement of number 2 seal on 'A' reactor coolant pump; and * On May 30, Unit 1, replacement of]]
1RW -57, 'A' river water pump (1
WR -P-1A) discharge check valve. b. Findings Introduction: A self-revealing Green
NCV of 10

CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" was identified for failure to specify and perform

an adequate PMT after replacing a safety-related river water check-valve. Specifically,

train 'A' river water was declared operable after replacement of check valve 1RW-57 per

work order 200233562 without an adequate PMT.

Enclosure Description: On May 25, 2009, the 'A' main intake bay was removed from service for planned bay cleaning. This rendered the 'A' safety-related river water pump (1WR-P-1A)

inoperable. The spare 'C' river water pump (1WR-P-1C) was aligned to service the 'A'

river train. During the bay cleaning, the 'A' river water pump discharge check valve

(1RW-57) was replaced on May 28 by mechanical maintenance per work order

200233562. This work order did not specify PMT requirements. The work order was

signed complete and the 'A' intake bay was returned to service on May 28. On May 29

the 'A' river water train was re-aligned, placing the 1WR-P-1A pump in service and

operable at 12:25 p.m. At 2:40 p.m., it was identified that PMT was not performed for

replacement of 1RW-57. The shift manager immediately declared 'A' train river water

inoperable and aligned the WR-P-1C to serve the 'A' river water train.

The inservice testing coordinator was contacted to identify post-maintenance testing

requirements.

ASME [[]]
OM Code, Section
IS [[]]

TC-5221 requires a forward flow and reverse-

closure verification for post-maintenance testing following a check valve replacement.

The PMT was accomplished satisfactorily on June 1.

The licensee's post-maintenance process failed to specify an adequate PMT for the

check valve replacement. The work order lacked any operational PMT and was the

apparent cause of the performance deficiency. The licensee documented this issue in

CR 09-59866.

Analysis: The failure to specify and perform a PMT after replacing a safety-related river water check-valve was a performance deficiency. The inspectors determined that the

performance deficiency was not similar to the examples for minor deficiencies contained

in IMC 0612, Appendix E, "Examples of Minor Issues". The finding was more than minor

in accordance with IMC 0612, Appendix B (Section 1-3), "Issue Screening," because the

failure to specify and perform a PMT is associated with the procedure quality

performance attribute of the mitigating systems cornerstone and affects the associated

cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

In accordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screening and

Characterization of Findings," the finding was determined to be of very low safety

significance (Green) because the finding was not a design or qualification deficiency

which resulted in a loss of function.

This finding has a crosscutting aspect in the area of human performance associated with

resources because the licensee did not have complete, accurate, and up-to-date

maintenance work procedures H.2(c).

Enforcement: 10 CFR 50, Appendix B, Criterion V, requires, in part, that procedures for performing maintenance that can affect the performance of safety-related equipment

should be properly preplanned and performed in accordance with written procedures,

documented instructions, or drawings appropriate to the circumstances. Contrary to this

requirement, in May 2009,

FENOC failed to specify and perform

PMT after replacement

of check value 1RW-57 prior to returning the system to operable status. Because this

deficiency is considered to be of very low safety significance (Green), and was entered

into the corrective action program (CR 09-59866), this violation is being treated as an

NCV , consistent with Section
VI.A. 1 of the
NRC Enforcement Policy. (

NCV

Enclosure 5000334/2009003-01, Inadequate Post-Maintenance Testing Specified for Safety-Related River Water Check Valve)

1R20 Refueling and Outage Activities (71111.20)

.2 Unit 1 Refueling Outage (1R19)

a. Inspection Scope (1 sample) The inspectors observed selected Unit 1 outage activities to determine whether

shutdown safety functions (e.g. reactor decay heat removal, spent fool pool cooling,

and containment integrity) were properly maintained as required by TS and plant

procedures. The inspectors evaluated specific performance attributes including operator

performance, communications, and instrumentation accuracy. The inspectors reviewed

procedures and/or observed selected activities associated with the refueling outage. The

inspectors verified activities were performed in accordance with procedures and verified

required acceptance criteria were met. The inspectors also verified that conditions

adverse to quality identified during performance of selected outage activities were

identified by the licensee's corrective action program. Documents reviewed are listed in

the Attachment. The inspectors also evaluated the following activities: * Pre-outage shutdown safety review / defense-in-depth reports; * Pre-outage temperature and power coastdown; * Reactor plant shutdown and cooldown, including evaluation of cooldown rates; * Solid plant operations; * Configuration management, compliance with

TS [[when taking equipment out of service; * Implementation of clearance activities and confirmation that tags were hung properly; * Status and configuration of electrical systems and switchyard activities; * Monitoring of decay heat removal and spent fuel cooling; * Fuel handling and activities that could affect reactivity; * Final containment walkdown and closeout inspection; * The digital video documenting the core reload and verification that fuel assembly placement was consistent with the reload map; * Subsequent shutdown and cooldown to replace 'A' reactor coolant pump seals after initial startup for physics testing; and * Final startup and power ascension to full power. During the refueling outage]]

FENOC identified a degradation of the containment liner

during planned containment inspections. The review of this issue is documented in a

separate report 05000334 / 2009006 (ADAMS ML091870328, on July 6, 2009). The

inspectors also verified that refueling outage activities were in compliance with TS during

the containment liner repair and retest. This issue was also reviewed for operability (section 1R15, 1R19) and event follow-up (section 4OA3.1)

The inspectors also observed selected management review activities associated with

restart readiness of Unit 1, following completion of the 1R19 refueling activities. The

restart readiness review meeting was accomplished as required by

NOBP -

OM-4010,

"Restart Readiness for Plant Outages" Rev. 4, during the week of May 11. The purpose

Enclosure of the review, in part, was to assure that the plant's material condition, programs/processes, and personnel were ready for startup and safe, reliable operation

after completion of outage activities.

b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope (8 samples: 1 isolation valve, 1 leak rate, 1 in-service testing and 5 routine.) The inspectors witnessed the performance of or reviewed test data for the eight following

Operation Surveillance Test (OST) and Maintenance Surveillance (MSP) packages. The reviews verified that the equipment or systems were being tested as required by

TS , the
UFS [[]]

AR, and procedural requirements. The inspectors also verified that the licensee

established proper test conditions, that no equipment pre-conditioning activities occurred,

and that acceptance criteria were met. * On March 26,

1OST [[-13.7B, Rev. 4, "Containment Depressurization System Operating Surveillance Test" [in-service testing]; * On April 14, 1]]
OST -1.04A, Rev. 0, "Train B,
CIA [[On-line Valve Relay Test" [isolation valve]; * On April 15, 1]]
OST -36.2, Rev. 51, "Diesel Generator No. 2 Monthly Test"; * On April 19,
1BVT -1.21.2, Rev. 15, "Trevitest Method for Main Steam Safety Valve Setpoint Check"; * On April 20, 1
OST -36.04, Rev. 25, "Diesel Generator No. 2 Automatic Test"; * On June 6,
1OST [[-15.1, Rev. 22, "[1]]
CC [[-P-1A] Quarterly Test"; * On May 10,]]
1OST -47.2B, Rev. 8, "Containment Closeout Inspection"; and * On June 24, Unit 2, 2

OST-6.2A, Rev. 27, "Computer Generated Reactor Coolant System Water Inventory Balance" [leak rate].

b. Findings No findings of significance were identified. 2.

RADIAT [[]]
ION [[]]
SAFETY [[Cornerstone: Occupational Radiation Safety []]

OS]

2OS1 Access Control to Radiologically Significant Areas (71121.01) a. Inspection Scope (10 samples) During the period April 27 - 30, the inspector conducted the following activities to verify

that the licensee was properly implementing physical, administrative, and engineering

controls for access to locked high radiation areas, and other radiologically controlled

areas during the Unit 1 refueling outage. Implementation of these controls was reviewed

against the criteria contained in

10 CFR 20, relevant

TS, and the licensee's procedures.

Enclosure This inspection activity represents the completion of ten (10) samples relative to this inspection area. Plant Walkdown and Radiation Work Permits (RWP) Reviews * The inspector toured accessible radiologically controlled areas in the Unit 1 reactor building containment (RBC), primary auxiliary building, and radwaste building and with the assistance of a radiation protection technician, performed independent

radiation surveys of selected areas to confirm the accuracy of survey data, and the

adequacy of postings. Radiation protection technicians were questioned regarding

their knowledge of plant radiological conditions for selected jobs, and the associated

controls. * The inspector identified radiologically significant jobs being performed in the Unit

1 RBC. The inspector reviewed the applicable
RWP s,
ALARA Plans (

AP), and the

electronic dosimeter dose/dose rate set points, for the associated tasks, to determine

if the radiological controls were acceptable and if the set points were consistent with

plant policy. Jobs reviewed included steam generator sludge lancing (RWP 109-

4015,

AP 09-1-24), insulation removal/replacement (

RWP 109-4032, AP 09-1-29),

remove/replace core exit thermocouples (RWP 109-4019, 09-1-26), and in-service

inspections (RWP 109-4023, AP 09-1-29). * For the jobs reviewed, the inspector determined that there were no significant dose gradients requiring relocation of dosimetry. The inspector determined that tele-

dosimetry was extensively used to monitor and control worker exposure for dose

intensive jobs. * There were no current radiation work permits for airborne radioactivity areas with the potential for individual worker internal exposures to exceed 50 mrem during the 1R19

outage. The inspector reviewed air sampling records for ongoing jobs to confirm that

airborne contamination was insignificant. * The inspector evaluated the effectiveness of contamination controls by reviewing personnel contamination event reports (and related condition reports), and observing

practices at various work locations in the RBC and at the step off pad. High Radiation Area and Very High Radiation Area Controls * The inspector reviewed procedures related to the control of high dose rate, high radiation area and very high radiation areas. The inspector discussed these

procedures with Radiation Protection Supervision to determine that any changes

made to these procedures did not reduce safety measures. * Keys to locked high radiation areas (LHRA) located in Unit 1 were inventoried, and accessible

LH [[]]

RAs were verified to be properly secured and posted during plant tours. * The inspector reviewed the preparations made for various potentially high dose rate jobs including removal of core exit thermocouples, and insulation modifications made

to various systems in the RBC. Included in this review were evaluating the

effectiveness of contamination control measures, source term controls, and use of

temporary shielding.

Enclosure Radiation Worker and Radiation Protection Technician Performance * During tours of radiologically controlled areas in the Unit 1 RBC, the inspector questioned radiation workers and radiation protection technicians regarding the

radiological conditions at the work site and the radiological controls that applied to

their task. Additionally, radiologically-related condition reports, including dose/dose

rate alarm reports, were reviewed to evaluate if the incidents were caused by

repetitive radiation worker or technician errors and to determine if an observable

pattern traceable to a similar cause was evident. * The inspector attended the pre-job

RWP briefings for a spent resin transfer, and for steam generator foreign object search and retrieval (

FOSAR) to determine if workers

were properly informed, including discussions of past operating experiences,

identification of the radiological conditions associated with their tasks, electronic

dosimetry dose/dose rate set points, and dose mitigation measures. Problem Identification and Resolution * The inspectors evaluated the licensee's program for assuring that access controls to radiologically significant areas were effective and properly implemented by reviewing

various Nuclear Oversight Field Observation Reports, radiation protection supervisory

daily logs, and relevant condition reports. The inspector determined if problems were

identified in a timely manner, that an extent of condition and cause evaluation were

performed when appropriate, previous radiation surveys remained valid, and

corrective actions were appropriate to preclude repetitive problems.

b. Findings No findings of significance were identified.

2OS 2

ALARA Planning and Controls (71121.02)

a. Inspection Scope (9 samples) During the period April 27 - 30, the inspector conducted the following activities to verify

that the licensee was properly implementing operational, engineering, and administrative

controls to maintain personnel exposure as low as is reasonably achievable (ALARA) for

activities performed in the 1R19 refueling outage. Implementation of these controls was

reviewed against the criteria contained in 10 CFR 20, and the licensee's procedures.

This inspection activity represents the completion of nine (9) samples relative to this

inspection area. Radiological Work Planning * The inspector reviewed pertinent information regarding site cumulative exposure history, current exposure trends, and the ongoing exposure challenges for the Unit 1

outage. The inspector reviewed the 1R19 Outage

ALA [[]]

RA Plan. * The inspector reviewed the exposure status for tasks performed during the Unit 1 outage and compared actual exposure with forecasted estimates contained in

Enclosure various project

ALARA Plans (
AP ). The inspector reviewed the Work-In-Progress
ALA [[]]

RA reviews for those jobs whose actual dose approached 75% of the forecasted

estimate. Outage jobs reviewed included scaffolding installation (AP 09-1-35),

insulation modifications (AP 09-01-33), reactor disassembly/reassembly (AP 09-1-

25), routine valve work (AP 09-1-41), and replacing incore detectors (AP 09-1-19). * The inspector evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing

ALA [[]]

RA program

elements and interface problems. The evaluation was accomplished by interviewing

site staff, reviewing outage Work-in-Progress reviews, attending a Station

ALA [[]]
RA Committee (SAC) meeting, and reviewing
SAC meeting minutes. The

SAC meeting

addressed planning for cutting/replacing a reactor coolant drain line (RC-41), and

revising the exposure estimate for insulation modifications. Verification of Dose Estimates * The inspector reviewed the assumptions and basis for the 1R19 outage

ALA [[]]

RA plan. The inspector also reviewed the revisions made to various outage project dose

estimates due to emergent work; e.g., insulation modifications (RWP 109-4048),

authorized by the Station

ALA [[]]

RA Committee. * The inspector reviewed the licensee's procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks was

approached and the implementation of these procedures during the outage. The

inspector reviewed the exposures for the ten (10) workers who received the highest

doses to confirm that no individual exceeded any regulatory limit. Job Site Inspections * The inspector reviewed the

ALARA controls specified for transferring resin from

CH-I-1A to a disposal container (RWP 109-0507,AP 09-1-58, procedure 1/2 -HPP-

3.03.007), and attended the pre-job

ALA [[]]

RA briefing. The inspector also reviewed the

controls used for manually transferring a spent filter (CH-FL-2) to a storage drum

(RWP 109-1020,

AP 09-1-11, procedure 1/2

OM-18.4A.E), the trouble shooting plan

for removing the filter when it became disengaged from the transfer grapple, and the

post-job debrief.

  • During tours of the
RBC , the inspector observed workers performing steam generator sludge lancing/

FOSAR (RWP 109-4015), eddy current testing on the recirculation

spray heat exchanger (RWP 109-4043), valve repairs, and de-mobilization activities. Workers were questioned regarding their knowledge of job site radiological

conditions and

ALA [[]]
RA measures applied to their tasks. Source Term Reduction and Control * The inspector reviewed the status and historical trends for the Unit 1 source term. Through review of survey maps and interviews with the Senior Nuclear Specialist-
ALA [[]]

RA, the inspector evaluated recent source term measurements and control

strategies. Specific strategies being employed included use of macro-porous clean

Enclosure up resin, zinc addition, increased filtration flow, enhanced chemistry controls, system flushes, and temporary shielding. Declared Pregnant Workers * The inspector reviewed the procedural controls for managing declared pregnant workers (DPW) and determined that no DPW was employed during the Unit 1

outage. Problem Identification and Resolution * The inspector reviewed elements of the licensee's corrective action program related to implementing the

ALA [[]]

RA program to determine if problems were being entered

into the program for timely resolution. Condition reports related to programmatic

dose challenges, personnel contaminations, and the effectiveness in predicting and

controlling worker exposure were reviewed.

b. Findings No findings of significance were identified. 4.

OTHER [[]]

ACTIVITIES [OA]

4OA1 Performance Indicator Verification (71151)

a. Inspection Scope (6 samples total) The inspectors sampled licensee submittals for Performance Indicators (PI) listed below

for both Unit 1 and Unit 2 to verify accuracy of the data recorded from April 2007 through

June 2009. The inspectors reviewed Licensee Event Reports, condition reports, portions

of various plant operating logs and reports, and PI data developed from monthly

operating reports. Methods for compiling and reporting the

PI s were discussed with cognizant engineering and licensing personnel. To verify the accuracy of the

PI data

reported during this period, PI definitions and guidance contained in Nuclear Energy

Institute (NEI) 99-02, "Regulatory Assessment Indicator Guideline," Revision 5, were

used for each data element.

Cornerstone: Mitigating Systems (2 samples) * Unit 1 and 2 Safety System Functional Failure [MS05]

Cornerstone: Barrier Integrity (4 samples) * Unit 1 and 2 Reactor Coolant System Activity [BI01] * Unit 1 and 2 Reactor Coolant System Leak Rate [BI02] b. Findings No findings of significance were identified.

Enclosure 4OA2 Problem Identification and Resolution (71152 - 2 samples total)

.1 Daily Review of Problem Identification and Resolution

a. Inspection Scope

As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"

and in order to help identify repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed a daily screening of items entered into

FEN [[]]

OC's corrective action program. This review was accomplished by reviewing

summary lists of each

CR , attending screening meetings, and accessing

FENOC's

computerized CR database.

b. Findings No findings of significance were identified.

.2 Annual Sample: Review of Final Cause and Corrective Actions of Inadvertent Unlatch of a Control Rod Drive Shaft during Refueling 2R13

a. Inspection Scope (1 sample) The inspectors selected

CR 08-39693 as a problem identification and resolution (

PI&R)

sample for a detailed follow-up review. CR 08-39693 documented on May 2, 2008, an

inadvertent unlatching of a control rod drive shaft during its transfer from its storage

location to its core location by vendor personnel after planned split pin replacements.

The tool used in the drive shaft installation was specific to the split pin replacement

project. Review of the initial event is documented in report 05000412 / 2008003.

The inspectors reviewed the vendor apparent cause and assessed

FEN [[]]

OC's cause

analysis, extent of condition, operability determination, and prioritization and timeliness of corrective actions to prevent recurrence. Documents reviewed for this inspection are

located in the Attachment.

b. Findings and Observations No findings of significance were identified.

The inspectors determined that

FEN [[]]

OC properly evaluated the degraded condition and

implemented appropriate immediate and long term corrective actions. The CR was

complete and included cause evaluations by

FEN [[]]

OC and the vendor. No human

performance deficiencies were noted. It was determined that the handing tool is not fail-

safe and can unlatch if the drive shaft weight is relieved by interference with a guide

card. The licensee discontinued use of the vendor's special tool during the issue and

has revised applicable procedures to prevent future use.

.3 Annual Sample: Review of Submerged Safety Related Cables a. Inspection Scope (1 sample)

Enclosure The inspectors selected

CR 08-42380 as a

PI&R sample for a detailed follow-up review. CR 08-42380 documented the identification of safety related cables found submerged in

water on June 25, 2008 for an indefinite period of time. The issue was identified during

routine manhole inspections. The inspectors assessed

FEN [[]]

OC's problem identification

threshold, operability determination, extent of condition review, and the prioritization and timeliness of corrective actions to determine whether

FEN [[]]

OC was appropriately

identifying, characterizing, and correcting problems associated with these issues and

whether the planned or completed corrective actions were appropriate to prevent

recurrence. Additionally, the inspectors observed manhole and cable inspections on

June 9-10, 2009 and interviewed engineering personnel. The inspectors reviewed the

specification, testing and long term moisture resistance qualification report for the subject

cables. Specific documents reviewed are listed in the attachment to this report.

b. Findings and Observations Introduction: The inspectors identified a non-cited violation (NCV) of

10CFR Part 50, Appendix B, Criterion
III , "Design Control," in that
FEN [[]]

OC did not maintain safety related cables in an environment for which they were designed. The licensee failed to

demonstrate that the cables are qualified for continuous submerged conditions, and that

they will remain operable, although the cables are presently operable.

Description: Safety related and non-safety related power and control cables may be submerged in water on a continuous basis. The affected cables included cables from

the Unit 1 River Water and Unit 2 Service Water from the Main Intake Structure carrying

power to the Class 1E load through electrical manholes

1EMH -8A and 1

EMH-8B.

A review of the licensing basis and licensee documentation reveals the cables are

selected and purchased for dry, wet, and immersed in water conditions. The inspectors

determined, after discussions with additional NRC specialists, that this does not include

continuous submerged conditions. The inspectors reviewed the specifications used to

purchase these cables and noted that the subject cables are not designed for continuous

submergance.

The environmental conditions in the manholes can be dry, wet, and immersed in water.

A review of the licensee's underground cable duct drawings showed that the manholes

are constructed below grade and expected to accumulate water. However, the cables

can become continuously submerged in water if the accumulation is not managed or

manhole degraded conditions not effectively corrected. Presently, the licensee relies on

cable penetration seal integrity and manual dewatering of the manholes annually (for

1EMH-8A and 8B only) or biennially to manage water accumulation. The most recent

inspection (June 9, 2009) of manholes identified approximately 2 feet of water in 1EMH-

8A and 11 feet of water in 1EMH-8B; conditions of apparent continuous submergence for

manhole 1EMH-8B cables. The licensee failed to ensure that the cables were

maintained in a design condition for the anticipated environmental conditions by not

thoroughly evaluating the effect of continuous cable submergence apparent in CRs

09-60591; 08-43594; 08-42380; 06-6305; 06-04144; 04-03545; 02-02348 and evaluating

the effectiveness of prior corrective actions.

The licensee had previously documented an engineering evaluation of cable suitability to submerged conditions (CR 02-02348, March 21, 2002) to address NRC Information

Notice 2002-12, Submerged Safety-Related Electrical Cables. The licensee concluded

Enclosure that based on cable construction, qualification testing performed, and operational performance, the cables in manholes 1EMH-8A and 8B were acceptable. This

evaluation had also been the basis for subsequent evaluations for as-found manhole

conditions. Corrective actions were taken to annually inspect and dewater the manholes

and address as-found degraded conditions, however the licensee has not adequately

addressed the apparent continuous submergence of safety related cables in the subject

manholes.

The licensee has pumped down water from the manholes to minimize water, and

inspected the cables, seals, and tray supports. An immediate operability assessment was also performed for as found conditions and CRs written (09-60316; 09-60445;

09-60591). The inspectors questioned the licensee on the need to re-evaluate the

frequency of manhole inspections, based on as-found conditions.

A review of the licensee's response to NRC Generic Letter 2007-01, "Inaccessible or

Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause

Plant Transients," did not identify any past cable failures at Beaver Valley.

Analysis: Failure to maintain safety related cables in an environment for which they were designed is considered a performance deficiency. The inspectors determined that the

performance deficiency was not similar to the examples for minor deficiencies contained

in IMC 0612, Appendix E, "Examples of Minor Issues". The finding was more than minor

in accordance with IMC 0612, Appendix B (Section 1-3), "Issue Screening," because if

left uncorrected, the performance deficiency has the potential to lead to a more

significant safety concern. Traditional enforcement does not apply since there were no

actual safety consequences or potential for impacting the NRC's regulatory function, and

the finding did not have willful aspects.

In accordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screening and

Characterization of Findings," the finding was determined to be of very low safety

significance (Green) because the finding was not a design or qualification deficiency

which resulted in a loss of operability or functionality, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train for

greater than its technical specification allowed outage time, did not represent an actual

loss of safety function of one or more non-technical specification trains of equipment

designated as risk-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not potentially risk

significant due to a seismic, flooding or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of Problem

Identification and Resolution, Corrective Action Program, because the licensee did not

thoroughly evaluate problems such as the resolutions, address causes, and evaluate the

effectiveness of corrective actions [P.1 (c)].

Enforcement: Title

10 CFR Part 50, Appendix B, Criterion

III, "Design Control," requires, in part, that measures shall be established to ensure that applicable regulatory

requirements and the design basis are correctly translated into specifications, drawings,

procedures, and instructions. Contrary to the above,

FEN [[]]

OC did not maintain safety

related cables in an environment for which they were designed. The issue was entered

into the licensee's corrective action program (CR 09-60496) to initiate a review of the

current manhole and cable monitoring programs, and to initiate long-term corrective

actions. Because this finding was of very low safety significance, and it was entered into

Enclosure the licensee's corrective action program, this violation is being treated as an

NCV , consistent with Section
VI.A. 1 of the
NRC Enforcement Policy. (

NCV 05000334, 412/2009003-02, Continuously Submerged Cables Design Deficiency) 4OA3 Followup of Events and Notices of Enforcement Discretion (71153 - 7 samples total)

.1 Plant Event Review a. Inspection Scope (6 samples) For the plant events below, the inspectors reviewed and/or observed plant parameters,

reviewed personnel performance, and evaluated performance of mitigating systems.

The inspectors communicated the plant events to regional personnel and compared the

event details with criteria contained in IMC 0309, "Reactive Inspection Decision Basis for

Reactors," for consideration of additional reactive inspection activities. The inspectors

reviewed

FEN [[]]

OC's follow-up actions related to the events to assure that appropriate

corrective actions were implemented commensurate with their safety significance.

Documents reviewed during the inspection are listed in the Attachment.

  • Unit 1: On April 20, 2009, main feedwater isolation (P14 actuation on high 'B' steam generator water level) during plant shutdown for refueling outage 1R19.

The high steam generator water level was caused by a failed main feedwater

bypass regulating valve (1FW-489) controller, causing it to inadvertently fully

open. Operators responded appropriately and mitigating systems performed as

designed. The licensee documented this issue in CR 09-57474. This issue was

also reviewed under

NRC Op

ESS FY2009-02, "Negative Trend and Recurring

Events Involving Feedwater Systems;" * Unit 1: On April 20, 2009, invalid actuation of the steam-driven auxiliary feedwater pump (FW-P-2) during plant shutdown for refueling outage 1R19. An apparent

failed solid state protection relay caused one of two steam admission valves (TV-

1MS-105B) to open, causing the pump to inject. The auxiliary feedwater flow control system responded appropriately to mitigate the effect on plant cooldown.

The licensee documented this issue in CR 09-57499. This issue was also

reviewed under

NRC Op

ESS FY2009-02, "Negative Trend and Recurring Events

Involving Feedwater Systems;" * Unit 1: On April 23, 2009, identification of a degraded containment liner plate during a planned visual inspection in refueling outage 1R19. The degradation

was repaired and declared operable on May 7, 2009. The licensee documented

this issue in CRs 09-57589 and 09-57762. Also see section 1R08, "Inservice

Inspection." This issue is documented in NRC Inspection Report

05000334/2009006 (ADAMS ML091870328, on July 6, 2009); * Unit 1: On April 26, 2009, identification of two circumferential ultrasonic examination indications on base material of a 2 inch reactor coolant loop drain

line (BV-1RC-41) on the 'A' loop hot leg. The drain line material was replaced

and returned to service. Also see section 1R08, "Inservice Inspection." The

licensee documented this issue in CR 09-58004;

Enclosure * Unit 1: On May 6, 2009, inadvertent train 'A' safety injection signal was generated, while in mode 5, due to a faulty safety injection block switch.

Operators responded appropriately and no safety injection actually occurred.

Faulty switches were replaced. The licensee documented this issue in CR 09-

58765; and * Unit 1 and Unit 2: On June 18, 2009, at 9:39 p.m., a dual-unit Unusual Event (UE) was declared in response to a fire alarm and CO2 system actuation in the

Emergency Response Facility (ERF) substation. The licensee entered emergency action level (EAL) 4.1. The onsite fire brigade responded and no fire

was discovered, and determined there was a spurious actuation of the CO2

system. The UE was terminated at 10:36 p.m. The licensee is still investigating

the cause, but is preliminarily attributed to a fire protection panel fault. The

licensee documented this issue in CR 09-60763.

b. Findings

No findings of significance were identified.

.2 Review of Licensee Event Reports (LERs) (1 sample) (Closed) LER 05000334/2009-001-00: Surveillance Test Inadvertently Violates Technical Specification 3.6.1 for Containment Operability.

During a planned surveillance flow test on one of two outside recirculation spray system (RSS) pumps while in Mode 1, the suction and discharge containment isolation valves on

the RSS train of piping were closed, but not de-energized. These valves receive an

auto-open signal during a phase 'B' containment isolation. After the test, when the pump

casing drain valve was opened to drain the system to restore to a normal configuration,

the operations crew realized that the containment isolation valves needed to be de-

energized in order to maintain containment operability. This condition existed in excess of seven hours, twice, during filling and draining sequences. This is contrary to the requirement in TS 3.6.1, "Containment". The crew immediately de-energized the

affected valves. The inspectors reviewed the LER, verified the appropriateness of corrective actions and

extent of condition reviews, interviewed engineers and licensed operators, and

completed a plant walkdown with

FEN [[]]

OC engineers to identify the pump casing drain

valve. Corrective actions include revising affected procedures to properly include TS

3.6.1. The enforcement aspects of the violation are discussed in Section 4OA7,

Licensee Identified Violations. This

LER is closed. 4

OA5 Other Activities .1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope During the inspection period, the inspectors conducted the following observations of

security force personnel and activities to ensure that the activities were consistent with

Enclosure licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working

hours. Specific examples include: * Observed operations within the central and secondary alarm stations; * Toured selected security towers and security officer response posts; * Observed security force shift turnover activities; and * Reviewed security logs and corrective action program documents which discussed security issues.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an

integral part of the inspectors' normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

.2 TI 2515/172, Reactor Coolant System Dissimilar Metal Butt Welds (Unit 1)

a. Inspection Scope Temporary Instruction, TI 2515/172 provides for confirmation that owners of pressurized-

water reactors (PWRs) have implemented the industry guidelines of the Materials

Reliability Program (MRP) -139 regarding nondestructive examination and evaluation of certain dissimilar metal (DM) welds in reactor coolant systems containing Alloy

600/82/182. The TI requires documentation of specific questions in an inspection report.

The questions and responses were previously documented in NRC Inspection Report

05000334, 412/2008003, Attachment

B. The hot and cold leg nozzle-to-safe end dissimilar metal (DM) welds of the "A" S/G were examined during this 1st period inspection interval (1R19 outage). These welds were Risk-Informed
ISI [[]]

UT examined during 1R19. During the S/G replacement project 1R17,

these particular nozzle welds were replaced with Alloy 52 and are resistant to stress-

corrosion cracking and are considered Category "A" welds per MRP-139, Revision 1, and

therefore the required examinations are per

ASME Section
XI. [[]]
ASME Section

XI, Table

IWB-2500-1, B5.70 requires a volumetric and surface exam once per interval of the

dissimilar metal welds for the S/G cold and hot leg nozzle-to-safe end welds. The

Risk-Informed examination of these

DM welds was only a

UT examination (no surface

exam) since these welds were selected in a particular piping segment per the Risk-

Informed,

ISI program that supersedes the

ASME Section XI Code exam. The inspector

reviewed the manual UT examination data records of the "A" S/G cold and hot leg

nozzle-to-safe-end

DM welds

RC-E-1A-N11 and RC-E-1A-N12.

b. Findings No findings of significance were identified. 4OA6 Meetings, Including Exit

Enclosure .1 Access Control /

ALA [[]]

RA Planning and Control The inspector presented the inspection results of 2S01 and 2S02 to Mr. Kevin Ostrowski,

Director of Site Operations, and other members of

FEN [[]]

OC staff, at the conclusion of the

inspection on April 30, 2009. No proprietary information is presented in this report.

.2 Inservice Inspection The inspector presented the inspection results 1R08 to Mr. Kevin Ostrowski, Director of

Site Operations, and other members of the

FENOC staff at the conclusion of the

ISI

inspection at an exit meeting on May 7, 2009. Some proprietary information was

reviewed during this inspection and was either returned or properly destroyed, but no

proprietary information is presented in this report.

.3 Problem Identification and Resolution Submerged Cable Focus Sample The inspectors presented the inspection results Mr. Peter Sena, Beaver Valley Site Vice

President, and other members of

FEN [[]]

OC staff, at the conclusion of the inspection on

June 11, 2009. No proprietary information is presented in this report.

.4 Quarterly Exit Meeting Summary On July 22, the inspectors presented the normal baseline inspection results to Mr. Ray

Lieb, Director of Site Operations, and other members of the

FEN [[]]

OC staff. The

inspectors confirmed that proprietary information was not retained at the conclusion of

the inspection period. 4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the

licensee and is a violation of

NRC requirements which meets the criteria of Section

VI of

the

NRC Enforcement Policy,
NUREG -1600, for being dispositioned as an
NCV. * Technical Specification 3.6.1, "Containment," requires that containment operability be maintained in Mode 1, restored within one hour, or the reactor be shutdown to Mode 3 within six hours. Contrary to this requirement,

FENOC failed

to maintain containment operability or restore containment operability in the allowed time. Specifically,

FEN [[]]
OC did not ensure containment isolation valves
MOV -1
RS -155B and
MOV -1

RS-156B were closed and de-energized prior to

opening the

1RS -P-2B pump casing drain valve. The issue was entered into
FENOC 's corrective action program as

CR 09-56250. The finding was more than

minor because it is associated with the configuration control attribute of the

barrier integrity cornerstone and affects the cornerstone objective of ensuring

containment boundary preservation under postulated design-basis accident

scenarios. The inspectors determined that the finding was of very low safety

significance (Green), based on IMC 0609, Appendix H, Table 4.1 because this is

a Type B finding and the affected pipe size is less than 2 inches in diameter.

ATTACH [[]]
MENT [[:]]
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION Attachment
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION [[]]
KEY [[]]
POINTS [[]]
OF [[]]

CONTACT Licensee personnel

G. Alberti Steam Generator Program Owner

S. Baker Site, Radiation Protection Manager

R. Bologna Plant Engineering, Manager

T.C rella Senior Radiation Protection Technician
J. Fontaine Supervisor,

ALARA

L. Freeland Director Performance Improvement

J. Freund Supervisor, Rad Operations Support

D. Girdwood Radiation Protection, Quality Assessor
D. Grabski
ISI Coordinator
T. Heimel

NDE Level III

W. Klinko, Diesel System Engineer

E. Lauck System Engineer

R. Lubert Electrical I&C/Plant Engineering, Supervisor

C. Miller Senior Radiation Protection Technician

J. Miller Site Fire Marshall

B. Murtagh Design, Supervisor

K. Ostrowski Director, Site Operations
J. Patterson
RCS System Engineer
R. Pucci Senior Nuclear Specialist -

ALARA

P. Sena Site Vice President

B. Sepelak Supervisor, Regulatory Compliance

D. Schwer Manager, Work Management

G. Storolis Unit 2 Shift Manager

J. Tweddell License Renewal

Other Personnel

D. Lew Director, Division of Reactor Projects,
NRC Region I
R. Mathew Team Leader,
NRC NRR
J. Rogge Branch Chief,

NRC Region I

L. Ryan Inspector, Pennsylvania Department of Radiation Protection
LIST [[]]
OF [[]]
ITEMS [[]]
OPENED ,
CLOSED ,
AND [[]]
DISCUS [[]]

SED Open/Closed

05000334 / 2009003-01 NCV Inadequate Post-Maintenance Testing Specified for Safety-Related River Water Check Valve. (Section 1R19)

05000334, 412 / 2009003-02

NCV Continuously Submerged Cables Design Deficiency. (Section 4

OA2.3)

Attachment Closed

05000334 / 2009001-00 LER Surveillance test Inadvertently Violates Technical Specification 3.6.1 for Containment Operability. (Section

4OA 3.2)
LIST [[]]
OF [[]]
DOCUME [[]]
NTS [[]]
REVIEW [[]]

ED Section 1R01: Adverse Weather Protection

Procedures 1/2OM-53C.4A.35.1, Rev. 4, "Degraded Grid,"

NOP -
OP -1003, Rev. 0, "Grid Reliability Protocol,"
NOP -

OP-1007, Rev. 5, "Risk Determination,"

Condition Reports 09-60033 09-60106

Work Orders 200150639

200316056

200317926

200319210

200319961

200320671

Miscellaneous

BV -

PA-09-02, Summer Readiness PMS not Completed by June 1st

Section 1R04: Equipment Alignment

Procedures 1DBD-24, Design Basis Document for Feedwater System

2OST-30.4, Service Water System A Header Valve Test

2DBD-30, Design Basis Document for Service Water System

2OM-30.4.D, Spare Service Water Pump Startup

Drawings 10080-RM-0411-001, Rev. 15, "Valve Oper No. Diagram Low/High Head Safety Injection

08700-RM-0436-001, Rev. 11, "Valve Oper No. Diagram Emergency Diesel Generator Air Start System" 8700-RM-0436-002, Rev. 9, "Valve Oper No. Diagram Emergency Diesel Gen. Fuel Oil System"

10080-RM-430-1,

VO [[]]

ND Service Water Supply & Distribution

10080-RM-430-2,

VO [[]]

ND Service Water Primary Cooling

10080-RM-430-3,

VO [[]]

ND Service Water Primary Cooling

Attachment Section 1R05: Fire Protection Procedures 1OST-33.21, Containment Penetrations Area Fire Protection Test

Condition Reports 02-11507 08-49244 09-57425* 09-57811 09-60284 09-60911

09-60761 09-60762

Miscellaneous Fire Protection Safe Shutdown Report; RTL# A1.080J, Addendum 28

RTL # A9.210X, Rev. 1
BV [[]]
PS Unit 1 Appendix R Report, Chapter 11
BVPS Pre-Fire Plan for
ERF Substation and ERF diesel generator building
BV [[]]

PS Event Logs, dated June 18, 2009

Section 1R06: Flood Protection Documents reviewed are listed in section

4OA 2 for this sample. Section 1R08: Inservice Inspection Procedures
NDE -VT-513, Visual Examination of the Reactor Vessel Bottom Mounted Instrumentation (BMI) Nozzles, Rev.
3 NDE -
UT -323, Ultrasonic Examination of Welds Joining Cast Austenitic Piping Components, Rev.
2 ISIE -

ECP-2, Steam Generator Examination Program, Rev. 21

1&2

ADM -2039,

BVPS ISI Ten-Year Plans, Rev. 8

1&2

ADM -0801,
ASME Section XI Repair/Replacement Program, Rev. 7
NOP -

ER-2001, Boric Acid Corrosion Control Program, Rev. 7

Unit 1/2,

NDE [[]]
GP -105, Evaluation of
PSI /
ISI Flaw Indications, Rev. 9 Unit 1/2, ADM-2096, Alloy 600/690 Management Program, Rev. 7
PWSCC Susceptibility Assessment of the Alloy 600 and Alloy 82/182 Components in Beaver Valley Units 1 and 2, dated December 2003
NDE Examination Reports
UT -09-1009, 2" socket welded
RCS drain line RC-41-1502-Q1, completed 4/28/09
UT -09-1062,
RC -E-1A-N-11, Nozzle to safe-end DM weld (Hot Leg), completed 5/6/09
UT -09-1063,
RC -E-1A-N-12, Nozzle to safe-end DM weld (Cold Leg), completed 5/6/09
PT -09-1003,
RH -1-1-A-01 to 02, Welded attachment support SH-40, completed 4/29/09
PT -09-1004,
RH -1-1-A-01 to 02, Welded attachment support SH-40, completed 5/01/09
UT -09-1055,
DLW -LOOP3-7-S-02, RCS "C" loop cold leg pipe girth weld, completed 5/5/09
UT -09-1039, 1
CNMT -Liner Area #3, completed 5/1/09
BOP -
MT -09-029,
BV -1-
RCBX , Primary Containment, Liner repair root pass, completed 5/4/09
BOP -
MT -09-031,
BV -1-
RCBX , Primary Containment, Liner plate final, completed 5/4/09
BOP -
MT -09-032,
BV -1-
RCBX , Primary Containment, Liner plate final, completed 5/4/09
BOP -
UT -09-161, Containment liner repair plate butt weld, 45-degree scan, completed 5/4/09
BOP -
UT -09-162, Containment liner repair plate butt weld, 60-degree scan, completed 5/4/09
BOP -
VT -09-042,
VT -1,
RBC Liner plate weld, completed 5/4/09
SG -

CDME-07-24, BV Unit 1 Steam Generator Degradation Assessment 1R18 Refueling Outage, Rev.1

Attachment Work Orders 200367661 200366975 200367239 200367242

Condition Reports 07-25709 09-52089 09-54434 09-57589 09-57762 09-57665

09-57804 09-58004 09-58156

Section 1R12: Maintenance Rule Implementation Procedures 1OST-15.1, Reactor Plant Component Cooling Water Pump Operating Surveillance Test Condition Reports 07-27037 09-60127 09-59359

Section 1R13: Maintenance Risk Assessment and Emergent Work Control Calculations 8700-DMC-1669, Rev. 1, Add. 1, "Time to RCS Boiling Calculation for the Pre-outage Shutdown Defense-in-Depth Report."

Procedures

NOP -

OP-1007, Rev. 5, "Risk Determination"

1/2-ADM-2033, "Risk Management Program"

Work Orders

Condition Reports 09-57463 09-58491 09-58771 09-58775 09-58815

Other 1R19 Defense-In-Depth review for April 21, 2009

Unit 1 Weekly Maintenance Risk Summary for the week of June 15, Revs. 0 & 2

Unit 2 Weekly Maintenance Risk Summary for the week of June 15, Revs. 0 & 2

Section 1R15: Operability Evaluations Calculations 8700-UR(B)-511

10080-UR(B)-510

241-UR(B)-427 Procedures 1OST-24.15B "Auxiliary Feedwater System Solid State Protection System Testing Train B"

Condition Reports 04-05251

06-01122

09-57966

09-58000

09-58798

09-59713

Attachment Miscellaneous Event Notification 45015, dated April 23, 2009

Engineering Change 09-0365-01, Repair Containment Liner Plate Hole

IN 2005-24

L-09-119,

10CFR 50.55a Request Number

BV1-IWE-2-2, dated April 28, 2009

Mode Hold Resolutions for 09-57589, 09-57762

NO [[]]
TF 600538028, 600538316
NUR [[]]

EG-1522, Assessment of Inservice Conditions of Safety-Related Nuclear Plant Structures

RIS 2009-02, Rev. 1, "Use of Containment Atmosphere Gaseous Radioactivity Monitors for

Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors"

TS [[]]

TF-513

WO 200124471, 200367013, 200367242

Unit 2 Fire Protection Safe Shutdown Report

Section 1R18: Plant Modifications

Condition Reports 09-57390

Regulatory Applicability Determination and 10 CFR 50.59 Screens 09-01453 09-0174

Procedures 1OM-52.4.R.1.F, Station Shutdown from 100% Power to Mode 5.

Drawings 8700-6.24-158 sheet1, Rev. 7

8700-6.24-158 sheet 8, Rev. 2

8700-6.24-158, sheet 9, Rev. 2

8700-RM-0430-001, Rev 30

8700-RM-407-1, Rev. 28

8700-2.19-0036, Rev. A

Work Orders 200359549 200359555 200313752 200313753

Miscellaneous

NUREG -0138,
NUREG -0224
EGG -

EA-5826, TER Evaluation Report of the Overpressure protection System for the Beaver

Valley Power Station Unit 1, dated March 1982.

Section 1R19: Post-Maintenance Testing

Procedures

1OST -36.2, Rev. 51, "Diesel Generator No. 2 Monthly Test"
1OM -36.4

AN, Rev. 2, "Diesel Generator No. 2 Fast Start"

Work Orders 200124471 200308605 200284373 200296714 200296713

200367242 200369010 200233562

Attachment Condition Reports 09-57435 09-57813 09-58940

Miscellanous Section 1R20: Refueling and Outage Activities

Procedures

1BVT -1.1.1, Rev. 4, "Rod Position Indication System Calibration Verification and Control Rod Drop Test" 1
BVT 2.1.1, Issue 1, Rev. 0, "Control Rod plant Exercise and Data Collection"
1OM -6.4.

AO, Rev. 20, "Isolating and Draining a Reactor Coolant Loop"

1OM-20.4E, Rev. 31, "Draining The Refueling Cavity"

1OM-50.4D, Rev. 49, "Reactor Startup From Mode 3 to Mode 2"

1OM -50.4L, Rev. 18, "Plant Heatup From Mode 6 to Mode 3"
1OM -50.4L, Rev. 18, "Plant Heatup From Mode 6 to Mode 3, Data Sheet 2:
RCS Heatup / Cooldown Determination" 1OM-52.4.K, Rev. 0, "Tavg Coastdown Operations"
1OM -52.4.R.1.F, Rev. 14, "Station Shutdown from 100% Power to Mode 5", Data Sheet 2:

RCS Cooldown Determination Tables. 1OST-47.2B, Rev. 7, "Containment Closeout Inspection"

1OST-49.2, Rev. 22, "Shutdown Margin Calculation (Plant Shutdown) (Updated for Cycle 19)"

1MSP-9.04-M, Rev. 8, "Containment Sump Inspection"

1RP-3.2, Issue 0, Rev. 3, "Fuel Transfer System"

1RP-3.26, Rev. 7, "Refueling Procedure Upper Internals Assembly Installation"

1RP-3.28, Rev. 4, "Lower Internals Assembly Removal / Installation"

1RST-2.1, Rev. 11, "Initial Approach to Criticality After Refueling"

1RST -2.2, Rev. 10, "Core Design Check Test"
NOBP -
OM -4010, Rev. 4, "Restart Readiness for Plant Outages"
NOBP -
WM -5003, Rev. 1, "FENOC Rigging and Lifting Manual"
NOP -
OP -1005, Rev. 10, "Shutdown Defense in Depth"
NOP -

WM-5003, Rev. 1, "Rigging, Lifting, and Load Handling"

Drawings 8700-02.102-0050, Rev. A, "General Arrangement Transfer System"

Cable Drive Installation, Transfer System -

BV [[]]

PS1, Rev. 1

Work Orders Repetitive Task 10001 99-0201123-000 200285260 600426477

Miscellaneous 1R19 Outage Handbook

Defense-In-Depth Report, 1R19, dated April 6, 2009 and updated May 16, 2009

Operating Experience Handbook for

BV 1R19
ECP 09-0035-001,

BV1 and BV2 Tave / Power Coastdown, Master Package

8700-02.102-0010,

UE&C Instruction Manual Cable Drive Fuel Transfer System
BV [[]]

PS-1 Shift Operating / Refueling Logs dated April 19 - May 22, 2009

BV Unit 1 Cycle 20 Loading Pattern Map and Verification Video, reviewed May 12, 2009
NUR [[]]

EG-0612

Primavera Schedule, 1R19

Attachment Condition Reports 09-57474

09-57499

09-57762

09-57106

09-57589

09-59677

09-59702

09-60367

09-60572

Section 1R22: Surveillance Testing Procedures

1OST -36.3, Train A
EDG Autoload Test
1BVT [[-2.15.1, Rev. 5, " Reactor Plant Component Cooling Water Pumps [1]]

CC-P-1A], [1CC-P-1B], [1CC-P-1C] Performance Curve Development"

Condition Reports 09-56250 09-57623 09-60127

Work Orders & Notifications

WO 200309388
NO [[]]

TF 600537878

Miscellaneous Unit 1 Shift Operating Logs dated March 26 - 28, 2009

Sections

2OS 1Access Control to Radiologically Significant Areas and 2
OS 2
ALA [[]]

RA Planning and Controls

Procedures 1/2-ADM-1601, Rev 15, Radiation Protection Standards

1/2-ADM-1611, Rev 9, Radiation Protection Administrative Guide

1/2-ADM-1621, Rev 3,

ALA [[]]

RA Program

1/2-ADM-1630, Rev 10, Radiation Worker Practices

1/2-ADM-1631, Rev 5, Exposure Control

1/2-HPP-3.02.004, Rev 4, Area Posting

1/2-HPP-3.03.007, Rev 3, Transfer of Highly Radioactive Material from Plant Systems to Solid Waste 1/2-HPP-3.04.002, Rev 5, Bioassay Administration

1/2-HPP-3.05.001, Rev 4, Exposure Authorization

1/2-HPP-3.07.002, Rev 5, Radiation Survey Methods

1/2-HPP-3.07.013, Rev 3, Barrier Checks

1/2-HPP-3.08.001, Rev 8, Radiological Work Permit

1/2-HPP-3.08.003, Rev 10, Radiation Barrier Key Control

1/2-HPP-3.08.005, Rev 4,

ALA [[]]

RA Review Program

1/2-HPP-3.08.006, Rev 1, Shielding

BVBP -
RP -0003, Rev 4, Dosimetry Practices
BVBP -

RP-0013, Rev 2, Radiation Protection Risk Assessment Process

Attachment

BVBP -
RP -0020, Rev 6,
RP Job Coverage General Guidance
NOP -WM-7001, Rev 0,
ALA [[]]
RA Program
NOP -
WM -7002, Rev 0, Operational
ALA [[]]
RA Program
NOP -
WM -7003, Rev 0, Radiation Work Permit
NOP -
WM -7017, Rev 0, Contamination Control Program
NOP -

WM-7021, Rev 1, Radiological Postings, Labeling, and Markings

1/2-OM-18.4A.E, Rev 6, Removal of Spent Filter Cartridge From Filter Transfer Cask Nuclear Oversight Field Observation Reports Week of 4/20-26/2009 Condition Reports 09-58093 09-58195 09-58182 09-58115 09-58029 09-58162

09-58104 09-58043 09-58042 09-57896 09-57877 09-57843

09-57918 09-57701 09-57747 09-57797 09-57790 09-57810

09-57914 09-57901 09-55024 09-56516 09-56588 09-57570

09-57882

ALA [[]]

RA Plans & related Work-in-Progress /Post-Job Reviews 09-01-35, Permanent Scaffolding

09-01-33, Insulation Modifications (except Cavity Work)

09-01-25, Reactor Disassembly

09-01-41, Routine Valve Work

09-01-19, Replace/Dispose of Incore Detectors

09-01-24, Secondary Side Steam Generator Sludge Lancing/FOSAR

09-01-58, Flush/Change Resin

09-01-11, Changeout/Replace

1CH -

FL-2 Filter

09-01-33, Insulation Removal/Replacement Modification

09-01-26, Remove/Replace Incore Detectors

09-01-29, In-Service Inspections

09-01-31, Scaffolding

ALA [[]]

RA Committee Meeting Minutes Meeting Nos. 09-01m/s, 09-02 m/s, 09-03 m/s, 09-04m/s, 09-05 m/s, 09-06 m, 09-07 m,

09-08 m, 09-09 m (m-manager's, s-subcommittee) Miscellaneous

ALARA Reports 1R19 Outage
ALARA Plan
EP [[]]

RI Standard Radiation Monitoring Program - Unit 1 Source Term Measurements

High Dose Individuals for 2009

Dose and Dose Rate Alarm Reports for 2009 Section

4OA 2: Problem Identification and Resolution Procedures

NORM-ER-3112, Rev. 1, Cable Monitoring

1/2-PMP-E-75-001, 4160 Rev. 8, VAC Motor Inspection and Lubrication

1/2-75-MANHOLE-1E, Rev. 4, Inspection of Manholes for Water Induced Damage Completed Procedures 1/2-PMP-E-75-001, 4160 VAC Motor Inspection and Lubrication, Rev. 8 dated 12/27/07

1/2-PMP-E-75-001, 4160 VAC Motor Inspection and Lubrication, Rev. 8 dated 02/08/08

Attachment 1/2-PMP-E-75-001,

4160 VAC Motor Inspection and Lubrication, Rev. 8 dated 08/15/08 1/2-

PMP-E-75-001, 4160 VAC Motor Inspection and Lubrication, Rev. 8 dated 07/01/08

1/2-PMP-E-75-001, 4160 VAC Motor Inspection and Lubrication, Rev. 8 dated 05/19/08

1/2-PMP-E-75-001, 4160 VAC Motor Inspection and Lubrication, Rev. 8 dated 02/24/08

1/2-75-MANHOLE-1E, Inspection of Manholes for Water Induced Damage, Rev. 4 dated 09/26/06 1/2-75-MANHOLE-1E, Inspection of Manholes for Water Induced Damage, Rev. 4 dated 11/07/08

Miscellaneous:

BV [[]]

UFSAR Unit 1, Rev. 20

Kerite Letter dated December 5, 1991

Kerite Letter dated February 18, 2009

GL 2007-01, Inaccessible of Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients
IN 2002-12, Submerged Safety-Related Electrical Cables
IEEE 400.2,

IEEE Guide for Field Testing of Shielded Power Cable Systems Using Very Low Frequency (VLF) Westinghouse Issue Report 08-124-M001

Condition Reports: 02-02302

2-02348

06-04144

06-06305

08-39693

08-42380

08-43594

09-60316

09-60387

Section 4OA3: Event Response

Condition Reports 09-57474

09-58477

09-58873

09-58900

09-58905

09-59155

09-60763

09-60768

Procedures 1/2-EPP-IP-1.1, Rev. 43, "Notifications", Att B. Unusual Event - Control Room

1/2-EPP-IP-1.2, Rev. 35, "Unusual Event"

1/2-EPP-IP-1.1.F01, Nuclear Power Plant Initial Notification Form, dated June 18, 2009

1OM -1.4.Z, Rev.0, "

ESF Signal Reset By Alternate Method"

Attachment Work Orders 200366604

200306521

200366962

200366752

200351634

200306527

200390431

Event Notification 45000, dated April 20, 2009

45001, dated April 20, 2009

45001 (retraction), dated May 12, 2009

45015, dated April 23, 2009

45022, dated April 26, 2009

45099, dated May 28, 2009

45143, dated June 18, 2009

Miscellaneous:

BV -
SA -09-018, Snapshot Self-Assessment for Unit 1 Inadvertent
SSPS Train A
SI Signal on May 6, 2009 Mode Hold Resolutions for CRs 09-57499, 09-57474, 09-57762, 09-57589, 09-58004
NRC Op

ESS 2009-02, "Negative Trend and Recurring Events Involving Feedwater Systems"

Shift Logs dated, June 18, 2009

Event Timeline, June 18, 2009

LIST [[]]
OF [[]]
ACRONY [[]]
MS ADM Administrative Procedure
ALA [[]]
RA As Low As is Reasonably Achievable
AP [[]]
ALARA Plan
AS [[]]
ME American Society of Mechanical Engineers
BA [[]]
CC Boric Acid Corrosion Control
BCO Basis for Continued Operations
BMI Bare Metal Inspection
BV [[]]

PS Beaver Valley Power Station

CFR Code of Federal Regulations

CR Condition Report(s)

DM Dissimilar Metal

DPW Declared Pregnant Workers

EAL Emergency Action Level
ERF Emergency Response Facility
FA Functionality Assessments
FEN [[]]
OC First Energy Nuclear Operating Company
FOS [[]]

AR Foreign Object Search and Retrieval

IOD Immediate Operability Determinations

IMC Inspection Manual Chapter

IP Inspection Procedure

ISI Inservice Inspection

LCO Limiting Conditions for Operations

Attachment

LER Licensee Event Report

LHRA Locked High Radiation Area

MR Maintenance Rule

MRP Materials Reliability Program

MSP Maintenance Surveillance Package

MT Magnetic Particle Testing

NDE Non-Destructive Examination

NRC Nuclear Regulatory Commission

NRR Nuclear Reactor Regulation
OD Operability Determinations

OST Operations Surveillance Test

PI Performance Indicator

PI&R Problem Identification and Resolution

PMT Post Maintenance Testing

POD Prompt Operability Determinations

PT Penetrant Testing

PWR Pressurized-Water Reactor

RBC Reactor Building Containment

RCS Reactor Coolant System

RHR Residual Heat Removal

RSS Recirculation Spray System

RWP Radiation Work Permit
SAC Station

ALARA Committee

SSC Structures, Systems, and Components

SG Steam Generator

TS Technical Specification

UE Unusual Event
UFS [[]]

AR Updated Final Safety Analysis Report

UT Ultrasonic Testing

VT Visual Testing